Wildfire Damages to Homes and Resources:
Understanding Causes and Reducing Losses
Kelsi Bracmort
Specialist in Agricultural Conservation and Natural Resources Policy
March 12, 2012
Congressional Research Service
7-5700
www.crs.gov
RL34517
CRS Report for Congress
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epared for Members and Committees of Congress
Wildfire Damages to Homes and Resources: Understanding Causes and Reducing Losses
Summary
Wildfires are getting more severe, with more acres and houses burned and more people at risk.
This results from excess biomass in the forests, due to past logging and grazing and a century of
fire suppression, combined with an expanding wildland-urban interface—more people and houses
in and near the forests—and climate change, exacerbating drought and insect and disease
problems. Some assert that current efforts to protect houses and to reduce biomass (through fuel
treatments, such as thinning) are inadequate, and that public objections to some of these activities
on federal lands raise costs and delay action. Others counter that proposals for federal lands allow
timber harvesting with substantial environmental damage and little fire protection. Congress is
addressing these issues through various legislative proposals and through funding for protection
programs.
Wildfires are inevitable—biomass, dry conditions, and lightning create fires. Some are surface
fires, which burn needles, grasses, and other fine fuels and leave most trees alive. Others are
crown fires, which are typically driven by high winds and burn biomass at all levels from the
ground through the tree tops. Many wildfires contain areas of both surface and crown fires.
Surface fires are relatively easy to control, but crown fires are difficult, if not impossible, to stop;
often, crown fires burn until they run out of fuel or the weather changes.
Homes can be ignited by direct contact with fire, by radiative heating, and by firebrands (burning
materials lifted by the wind or the fire’s own convection column). Protection of homes must
address all three. Research has identified the keys to protecting structures: having a non-
flammable roof; clearing burnable materials that abut the house (e.g., plants, flammable mulch,
woodpiles, wooden decks); and landscaping to create a defensible space around the structure.
Wildland and resource damages from fire vary widely, depending on the nature of the ecosystem
as well as on site-specific conditions. Surface fire ecosystems, which burn on 5- to 35-year
cycles, can be damaged by crown fires due to unnatural fuel accumulations and fuel ladders
(small trees and dense undergrowth); fuel treatments probably prevent some crown fires in such
ecosystems. Stand-replacement fire ecosystems are those where crown fires are natural and the
species are adapted to periodic crown fires; fuel treatments are unlikely to alter the historic fire
regime of such ecosystems. In mixed-intensity fire ecosystems, where a mix of surface and crown
fires is historically normal, it is unclear whether fuel treatments would alter wildfire patterns.
Prescribed burning (intentional fires) and mechanical treatments (cutting and removing some
trees) can reduce resource damages caused by wildfires in some ecosystems. However, prescribed
fires are risky, mechanical treatments can cause other ecological damages, and both are
expensive. Proponents of more treatment advocate expedited processes for environmental and
public review of projects to hasten action and cut costs, but others caution that inadequate review
can allow unintended damages with few fire protection benefits.
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Wildfire Damages to Homes and Resources: Understanding Causes and Reducing Losses
Contents
Background: Fires Happen .............................................................................................................. 1
Protecting Structures from Wildfires ............................................................................................... 2
Home Ignitability....................................................................................................................... 3
Responsibility for Protecting Structures.................................................................................... 4
Protecting Wildlands and Natural Resources................................................................................... 6
Wildland Ecosystems and Wildfire ........................................................................................... 6
Surface Fire Ecosystems ..................................................................................................... 6
Stand-Replacement Fire/Crown Fire Ecosystems ............................................................... 7
Mixed-Fire-Intensity Ecosystems ....................................................................................... 8
Wildfire Effects ................................................................................................................... 8
Protecting Wildlands and Resources ......................................................................................... 9
Prescribed Burning............................................................................................................ 10
Mechanical Treatment ....................................................................................................... 11
Combined Operations........................................................................................................ 13
Area Needing Treatment ................................................................................................... 14
Delays and Changes in Federal Decision-Making................................................................... 16
ESA Consultations............................................................................................................. 17
NEPA Environmental Analysis and Public Involvement .................................................. 18
Forest Service Appeals Reform Act .................................................................................. 20
Expedited Procedures........................................................................................................ 21
Conclusions.................................................................................................................................... 24
Tables
Table 1. Lands at Risk of Ecological Damage from Wildfire, by Landowner Group and
Historical Fire Regime................................................................................................................ 14
Appendixes
Appendix. Excerpts from Forest Service Handbook on NEPA Categorical Exclusions
Related to Structural or Resource Protection From Wildfires .................................................... 25
Contacts
Author Contact Information........................................................................................................... 27
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Wildfire Damages to Homes and Resources: Understanding Causes and Reducing Losses
ildfires have been getting more severe in recent fire seasons; the 2004, 2005, 2006,
2007, and 2011 seasons were the most severe since 1960.1 An escaped prescribed fire
W that burned 239 houses in Los Alamos, NM, in May 2000 focused national attention on
the growing wildfire problem. The fire in Los Alamos highlighted the wildland-urban interface
problem.2 At that time, 2000 was the second most severe fire season since 1960, eclipsed only by
the 1988 Yellowstone fires.3 President Clinton responded with a new National Fire Plan to
increase funding for wildfire protection.
It has been widely proclaimed that the increasing severity of wildfires is a result of excessive
biomass accumulations. In at least some ecosystems, logging, livestock grazing, and a century of
fire suppression efforts have allowed biomass fuels to accumulate to unnatural levels. Climate
change, and its impacts on drought, fire, and insects and diseases, could exacerbate these
problems. Many interests have proposed fuel reduction treatments as a means to lower the fuel
levels and thus reduce the wildfire threat to homes and to wildlands. The severe 2002 fire season
led President Bush to propose a Healthy Forests Initiative to expedite efforts to reduce biomass
fuels on federal lands, and in 2003, Congress enacted the Healthy Forests Restoration Act to
expedite federal fuel reduction and other forest protection programs.
Some interests are concerned that current efforts to reduce fuel levels on federal lands are
inadequate, and that “environmentalist objections” to some of those efforts are unnecessarily
raising costs and delaying action. Others counter that some efforts are so broad that they permit
substantial timber sales without significantly reducing wildfire risks for communities. Congress
continues to address these issues as it considers funding and legislative proposals.
This report focuses on options for protecting structures and for protecting wildlands and natural
resources from wildfires. It begins with a brief overview of the nature of wildfires, followed by a
discussion of protecting structures. Then, it discusses wildfire damages to wildlands and natural
resources, fuel treatment options and their benefits and limitations, and public involvement in
federal decisions.
Background: Fires Happen
In temperate ecosystems, wildfires are inevitable. The combination of biomass plus dry
conditions—in the short term (e.g., the annual dry season) or in the long term (e.g., drought or
climate change)—equals fuel to burn. Add an ignition source, such as lightning, and wildfire
happens. Fire is a self-sustaining chemical reaction that perpetuates itself as long as all three
1 National Interagency Fire Center, “Total Wildland Fires and Acres,” at http://www.nifc.gov/fireInfo/
fireInfo_stats_totalFires.html. Fire season severity is commonly assessed by acres burned, but larger fires may not be
“worse” if they burn less intensely, because their damages may be lower. However, fire intensity and damages are not
measured for each wildfire, and thus cannot be used to gauge the severity of fire seasons. It is unclear whether acreage
burned might be a reasonable approximation of severity.
2 The wildland-urban interface is an area where structures (usually homes) are in or near wildlands (forests or
rangelands). For more information, see CRS Report RS21880, Wildfire Protection in the Wildland-Urban Interface, by
Ross W. Gorte and Kelsi Bracmort.
3 Subsequent fire seasons have surpassed the 2000 season, while the 1988 data have been revised downward.
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elements of the fire triangle—fuel, heat, and oxygen—remain available. Fire control focuses on
removing one of those elements.
There are two principal kinds of wildfire, although an individual wildfire may contain areas of
both kinds.4 One is a surface fire, which burns the needles or leaves, grass, and other small
biomass within a foot or so of the ground and quickly moves on. Such fires are relatively easy to
control by removing fuel with a fireline, essentially a dirt path wide enough to eliminate the
continuous fuels needed to sustain the fire, or by cooling or smothering the flames with water or
dirt.
The other principal kind of wildfire is a crown fire, also called a conflagration. Crown fires burn
biomass at all levels—from the surface through the tops of the crowns of the trees—although they
do not consume all the biomass; logs and large limbs may need to burn for hours before being
completely reduced to ashes. Rather, a crown fire quickly burns the needles or leaves and small
twigs and limbs on the surface and throughout the crown of the trees. Because the needles and
leaves in the crown are green, they require more energy to burn than dry fuels on the surface.
Furthermore, because of the green fuels and the often discontinuous biomass of the canopy, wind
is usually needed to sustain a crown fire. Once burning vigorously, a crown fire can create its own
wind (the strong upward convection of the heated air can draw in cooler air from surrounding
areas, thus creating a wind that feeds the fire). The strong upward convection can also lift burning
biomass (firebrands) and send it soaring ahead of the fire, creating spot fires and accelerating the
spread of the wildfire. Crown fires typically include areas of surface fire and unburned areas
within their perimeters.
Not surprisingly, crown fires are difficult, if not impossible, to control. Unless quite wide,
firelines may be ineffective to control crown fires, especially if winds are causing spot fires.
Water or fire retardant (slurry) dropped from helicopters or airplanes can sometimes knock a
crown fire down (back to a surface fire) if the area burning and the winds are not too great. Often,
however, crown fires burn until they run out of fuel or the weather changes (the wind dies or it
rains or snows).
Nearly all fires are “patchy,” with a mix of areas of varying fire severities, depending on site-
specific fuel, moisture, and wind conditions. This patchiness makes understanding and controlling
wildfires difficult at best.
Protecting Structures from Wildfires
Wildfires occasionally burn houses, in a zone commonly called the wildland-urban interface.5 In
recent years, it seems one or more fires annually have burned down several to a few hundred
homes and outbuildings (sheds, garages, etc.). These structures generally have ignited in one of
three ways: through direct contact with fire, through radiation (heating from exposure to flames),
4 See Stephen F. Arno and Steven Allison-Bunnell, Flames in Our Forest: Disaster or Renewal? (Washington, DC:
Island Press, 2002), pp. 45-46.
5 For information on the interface, see CRS Report RS21880, Wildfire Protection in the Wildland-Urban Interface, by
Ross W. Gorte and Kelsi Bracmort.
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and through firebrands.6 The likelihood of a structure burning from one of these ignition methods
is called home ignitability.7
Home Ignitability
Research has identified three essential elements to protecting structures: the roof; adjacent
burnable materials; and the landscaping. Treating these three elements addresses all three ways by
which structures are ignited—direct contact, radiation, and firebrands.
The roof is critical to protecting structures from wildfires.8 Firebrands that land on a flammable
roof can ignite the roof. Untreated red cedar shakes and shingles are particularly problematic: “A
major cause of home loss in wildland areas is flammable woodshake roofs.”9 Fire retardant
treatments are sufficient for wood shakes, but the effectiveness of such treatments degrades over
time.10 Alternatives include tile, slate, metals (e.g., copper or aluminum), and other non-
flammable materials. Walls, doors and windows, and vents can also contribute to the protection,
or destruction, of a structure, depending on materials, location, and other variables.11
Adjacent burnable materials are items that can burn that abut the house. This can include plants
(live or dead) and flammable mulch (e.g., wood chips or bark) under an overhang or eave or next
to the structure, gutters clogged with leaves or needles, decks and porches, sheds and garages, and
especially woodpiles. These factors were particularly important for the 239 homes burned by the
Cerro Grande fire in Los Alamos, NM, in May 2000: “The high ignitability of Los Alamos was
principally due to the abundance and ubiquity of pine needles, dead leaves, cured vegetation,
flammable shrubs, and wood piles that were adjacent to, touching, or covering parts of homes.”12
One source recommended that “when assessing the ignition potential of a structure, attachments
[such as decks, porches, and fences] are considered part of the structure.”13
Finally, landscaping—the character of the vegetation surrounding the house—is critical to
preventing both direct burning and ignition by radiation. Recommended defensible space around
structures is at least 30 feet or 10 meters, with greater distances for steeper slopes (because of up-
slope convection heating) and for larger vegetation (least for grass, more for shrubs, most for
mature forest).14 Others recommend greater distances, such as 100 feet.15 One researcher
6 National Wildland/Urban Interface, Fire Protection Program, Wildland/Urban Interface Fire Hazard Assessment
Methodology, p. 5, at http://www.firewise.org/resources/files/wham.pdf.
7 Jack D. Cohen, “Preventing Disaster: Home Ignitability in the Wildland-Urban Interface,” Journal of Forestry (March
2000), p. 17.
8 FireSmart: Protecting Your Community From Wildfire (Edmonton, Alberta: Partners in Protection, May 1999), pp. 2-
5.
9 Wildland/Urban Interface Fire Hazard Assessment Methodology, p. 7.
10 Is Your Home Protected From Wildfire Disaster? A Homeowner’s Guide to Wildfire Retrofit (Tampa, FL: Institute
for Business and Home Safety, n.d.), p. 9, at http://www.firewise.org/resources/files/wildfr2.pdf.
11 Wildland/Urban Interface Fire Hazard Assessment Methodology, p. 7.
12 Jack Cohen, “The Cerro Grande Fire: Why Houses Burned,” Forest Trust Quarterly Report, no. 23 (Dec. 2000), p. 7.
13 Wildland/Urban Interface Fire Hazard Assessment Methodology, p. 7.
14 FireSmart, pp. 2-11, and Robert Bardon and Robin Carter, Minimizing Wildfire Risk—A Forest Landowner’s Guide,
03/03-30M-DSB/SSS AG-616 (North Carolina Cooperative Extension Service, n.d.), p. 6.
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calculated that the ignition time for an untreated wood wall was more than 10 minutes at a
distance of 40 meters (about 130 feet).16 With burning durations for crown fires “on the order of 1
minute at a specific location,” the “safe distance” for an untreated wood wall was calculated to be
27 meters (less than 90 feet), which is consistent with field tests documenting wall ignition times
for experimental crown fires in Canada.17 The same source notes older fire case studies
documenting structure survival—95% survival for 10-18 meter (about 32-60 feet) clearance in the
1961 Belair-Brentwood (CA) fire and 86% survival for 10+ meter clearance in the 1990 Painted
Cave (CA) fire.18 Thus, clearing to 40 meters would likely be considered ideal, to 30 meters
desirable, and to at least 10 meters essential to achieving about 90% probability of survival. Note
also that “clearing a defensible space” does not require an expanse of concrete or gravel;
relatively non-flammable vegetation, such as a lawn or succulent, herbaceous plants and flowers,
can provide comparable protection.19
The importance of landscapes in protecting structures can also be deduced from evidence from
the 2002 Hayman fire, the largest wildfire in Colorado history. A total of 132 homes were burned
in the Hayman fire. Of these, 70 (53%) “were destroyed in association with the occurrence of
torching or crown fire in the home ignition zone. Sixty-two [47%] were destroyed by surface fire
or firebrands.”20 Conversely, 662 homes—83% of the homes within the fire perimeter—survived
the Hayman fire relatively unscathed.21 Since 35% of the Hayman fire was a high-severity burn,
and another 16% was a moderate-severity burn,22 it seems likely that at least some of these homes
(the number and portion are not documented) survived despite crown fire around them. Thus, it
seems reasonable to conclude that the nature of the structure—rather the nature of the fire—
primarily determines whether a structure survives a wildfire.
Responsibility for Protecting Structures
Owners are responsible for their structures. Insurance companies and the relevant state agencies
that regulate insurance can contribute to structural protection by requiring certain materials and
actions to obtain a policy for compensation following wildfire losses or by adjusting premiums
based on homeowner actions. Local governmental agencies also play a role, since the building
and zoning codes that could implement some of the safe-structure requirements are generally
(...continued)
15 Wildland/Urban Interface Fire Hazard Assessment Methodology, p. 7.
16 Jack D. Cohen, “Reducing the Wildland Fire Threat to Homes: Where and How Much?” Proceedings of the
Symposium on Fire Economics, Planning, and Policy: Bottom Lines, Gen. Tech. Rept. PSW-GTR-173 (Berkeley, CA:
USDA Forest Service, Pacific Southwest Research Station, Dec. 1999), pp. 189-195.
17 Cohen, “Reducing the Wildland Fire Threat to Homes,” p. 191.
18 Cohen, “Reducing the Wildland Fire Threat to Homes,” pp. 191-192.
19 FireSmart, pp. 2-16.
20 Jack Cohen and Rick Stratton, “Home Destruction Within the Hayman Fire Perimeter,” Hayman Fire Case Study,
Gen. Tech. Rept. RMRS-GTR-114 (Ft. Collins, CO: USDA Forest Service, Rocky Mountain Research Station, Sept.
2003): p. 264.
21 Cohen and Stratton, “Home Destruction Within the Hayman Fire Perimeter,” p. 263.
22 Peter Robichaud, Lee MacDonald, Jeff Freeouf, Dan Neary, Deborah Martin, and Louise Ashman, “Postfire
Rehabilitation of the Hayman Fire,” Hayman Fire Case Study, Gen. Tech. Rept. RMRS-GTR-114 (Ft. Collins, CO:
USDA Forest Service, Rocky Mountain Research Station, Sept. 2003), p. 294.
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developed and enforced locally.23 Alternatively, states can play a role; as of January 1, 2008, the
California Building Standards Commission24 is enforcing wildland-urban interface building
standards in very high hazard zones.
The structure owners are also primarily responsible for the defensible space surrounding their
structures. A 10-meter-wide clearing around a 3,000-square-foot structure encompasses less than
a third of an acre—almost certainly private land owned in conjunction with the structure. Even a
40-meter clearing encompasses less than 2 acres, and thus is commonly part of the structure
owner’s property in the wildland-urban interface.
When a structural fire starts, the local fire department is responsible for controlling the blaze.
State agencies may provide support for local fire departments, especially in the wildland-urban
interface where a structural fire could cause a wildland fire. Occasionally, because of the location
of firefighting resources, the federal agencies may be the first responders on a structural fire in
the interface, but federal firefighters are generally not trained for safety in structural firefighting.
The federal government has no responsibility for structural fire control in the wildland-urban
interface. However, the Forest Service (FS) does have programs to provide technical and financial
assistance to states and to volunteer fire departments.25
Given the nature of efforts needed to protect structures and the fact that developing, adopting, and
enforcing building codes are local and state responsibilities, there is no clear federal responsibility
in protecting structures from wildfires. However, the federal government often provides disaster
assistance in the wake of a catastrophic wildfire, generally at the request of a governor. Federal
disaster assistance is expensive and could be avoided if action to protect homes were taken in
advance. Several federal agencies currently support FIREWISE, a program aimed at educating
homeowners about how to make their structures safe from wildfire.26 Assistance to
homeowners—such as technical assistance, low-cost loans, and cost-sharing on projects—might
be a cost-saving federal investment. Federal assistance to prepare local firefighters is another
means for addressing home protection from wildfires.27 Research on wildland-urban interface fire
protection can also reduce losses.28 Another possibility might be federal wildfire insurance,
23 Model building codes for local governments exist. For example, in 2012, the International Code Council (ICC)
published its International Wildland-Urban Interface Code (http://www.iccsafe.org/Store/Pages/Product.aspx?id=
3850X12#longdesc), with a separate chapter on ignition-resistant construction specifications. In June 2007, the
National Fire Protection Association (NFPA) approved an updated standard, Standard for Reducing Structure Ignition
Hazards from Wildland Fire, http://www.nfpa.org/aboutthecodes/AboutTheCodes.asp?DocNum=1144.
24 See http://www.bsc.ca.gov/default.htm.
25 For a description of these programs, see CRS Report RL31065, Forestry Assistance Programs, by Ross W. Gorte
and Megan Stubbs.
26 FIREWISE is part of the National Wildland/Urban Interface Fire Program, directed and sponsored by the
Wildland/Urban Interface Working Team, which includes the USDA Forest Service, several DOI agencies (the Bureau
of Land Management, Bureau of Indian Affairs, Fish and Wildlife Service, and National Park Service), and two
agencies of the Department of Homeland Security (the Federal Emergency Management Agency and U.S. Fire
Administration). It also includes the International Association of Fire Chiefs, National Association of State Fire
Marshals, National Association of State Foresters, National Emergency Management Association, and National Fire
Protection Association.
27 See the program announced by the U.S. Fire Administration and the National Wildfire Coordinating Group, at
https://www.usfa.dhs.gov/media/press/2008releases/012308.shtm.
28 See the U.S. Forest Service Wildland-Urban Fire Models website, at http://www.fs.fed.us/pnw/fera/research/wfds/.
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comparable to the National Flood Insurance Program.29 Those living in an identified wildfire-
prone zone would be required to purchase federal wildfire insurance (probably with an annual
premium) to receive compensation for wildfire damages. The premiums could vary by eco-
region, depending on the likelihood and risk of wildfires, and by aspects of the structure and
landscaping (which might require periodic inspections).
Protecting Wildlands and Natural Resources
Wildlands and natural resources can also be damaged by wildfires. Wildfire damages vary widely,
depending on the nature of the ecosystems burned as well as site-specific conditions. Activities to
modify wildland biomass fuels can reduce damages, although the cost and effectiveness also vary.
Finally, for fuel reduction activities on federal lands, delays and modifications—related to
endangered species concerns and public involvement in decision-making—can affect the cost of
fuel treatments.
Wildland Ecosystems and Wildfire
Ecosystem fire regimes can be classified in several ways; one common approach is to distinguish
among surface fire ecosystems, stand-replacement fire ecosystems, and mixed fire ecosystems.30
Damages to lands and resources depend on the nature of those ecosystems.
Surface Fire Ecosystems
Surface fire ecosystems are ecosystems where fires burn relatively frequently (typically 5- to 35-
year intervals), with the fires consuming leaves or needles, grasses, twigs and small branches, and
sometimes small trees, but generally leaving moderate and large trees unharmed by the fire. The
classic surface fire ecosystem is the western Ponderosa pine, where seedlings occasionally
survive the surface fire to become the scattered, stately pines in fields of grass or low brush. The
other archetypical surface fire ecosystem is that of the southern yellow pines—shortleaf, slash,
loblolly, and especially longleaf pine. Surface fire ecosystems account for about 34% of all U.S.
wildlands.31
Over the past century, surface fire ecosystems in the West have been affected by grazing, logging,
and fire protection. Heavy grazing reduced grass cover, which commonly carried the surface
fires. Logging in many areas emphasized large pines, often leaving true firs and Douglas firs
(which are more susceptible to drought, insect damage, and crown fires) to replace the pines, at
least in the northern Rockies and Pacific Northwest. Fire protection has similarly led to more firs
and Douglas firs, and small Ponderosa pines, than would typically have survived. With fire return
29 For information on this program, see CRS Report RS22394, National Flood Insurance Program: Treasury
Borrowing in the Aftermath of Hurricane Katrina, by Rawle O. King.
30 Arno and Allison-Bunnell, Flames in Our Forest, pp. 44-45.
31 Fire Modeling Institute, Historical Fire Regimes by Current Condition Classes: Data Summary Tables (Missoula,
MT: USDA Forest Service, Rocky Mountain Research Station, Feb. 22, 2001), at http://www.fs.fed.us/fire/fuelman/
data_summary_tables.pdf.
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intervals of 5-35 years (i.e., fires typically burning once in that period), many surface fire
ecosystems have missed two or more burning cycles. Thus, many forests now have an unnaturally
large accumulation of small burnable materials and of trees susceptible to crown fires.
Many are concerned that the unnatural fuel accumulations and fuel ladders (continuous fuels
from the ground to the tree crowns) from many small and medium-sized pines, firs, and Douglas
firs are causing crown fires in ecosystems where such fires were rare. This could result in
significant ecological damage to plants and animals ill-adapted to crown fires. It is unclear
whether a new surface fire ecosystem will develop in the wake of an intense crown fire.
Research on fuel reduction treatments (discussed below) has documented the effectiveness of
such treatments on Ponderosa pine (a surface fire ecosystem),32 and activities that reduce fuel
accumulations have been shown to reduce wildfire severity in surface fire ecosystems.33
Presumably, less severe wildfires cause less damage to timber, to watersheds, and to wildlife and
wildlife habitats.
Stand-Replacement Fire/Crown Fire Ecosystems
Stand-replacement fire ecosystems are those where crown fires are normal, natural, periodic
events to which the ecosystem has adapted. The interval for the stand-replacement fires varies
widely—from a few years (prairie grasses) to more than 1,000 years (coastal Douglas fir)—
depending on the ecosystem. Some ecosystems require periodic crown fires to regenerate the
ecosystem. For example, lodgepole pine in much of the West and jack pine in the Lake States
have serotinous cones, which only open and release their seeds after exposure to temperatures
exceeding 250° Fahrenheit. Similarly, chaparral in southern California and the desert Southwest,
most perennial grasses, and aspen everywhere regenerate from rootstocks; burning the surface
vegetation allows new plants to sprout from the underground stems, rhizomes, and root crowns.
Stand-replacement fire ecosystems account for about 42% of all U.S. wildlands.34
It seems unlikely that stand-replacement fire ecosystems could suffer significant ecological
damage from severe wildfires. In contrast to surface fire ecosystems, where crown fires could
alter the ecosystem, in stand-replacement fire ecosystems, the exclusion of crown fires (if it were
possible) would likely alter the ecosystems. This ecological change is implied by evidence from
grass ecosystems (prairies and meadows), where fire suppression is feasible and which are being
encroached upon by trees that would normally have been eliminated by the frequent fires.
Activities that reduce fuel levels in stand-replacement fire ecosystems have no documented effect
on wildfire severity. Anecdotal reports have asserted that crown fires were halted (became surface
fires) when they arrived at treated areas, but research has not documented where and when such
32 Russell T. Graham, Alan E. Harvey, Theresa B. Jain, and Jonalea R. Tonn, The Effects of Thinning and Similar Stand
Treatments on Fire Behavior in Western Forests, Gen. Tech. Rept. PNW-GTR-463 (Portland, OR: USDA Forest
Service, Pacific Northwest Research Station, 1999).
33 Philip N. Omi and Erik J. Martinson, Final Report: Effect of Fuels Treatment on Wildfire Severity, submitted to the
Joint Fire Science Program Governing Board (Ft. Collins, CO: Colorado State Univ., Western Forest Fire Research
Center, Mar. 25, 2002).
34 Historical Fire Regimes by Current Condition Classes.
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occurrences have happened. To date, no research has shown that fuel treatments consistently
reduce the extent or severity of wildfires in stand-replacement fire ecosystems. The
ineffectiveness of fuel reduction was particularly noted for southern California chaparral: “large
fires were not dependent on old age classes of fuels, and it is thus unlikely that age class
manipulation of fuels can prevent large fires.”35
Mixed-Fire-Intensity Ecosystems
Many wildlands have ecosystems that burn in crown fires of relatively limited scale, substantially
mixed with surface fires. These ecosystems are called mixed-fire-intensity ecosystems. A classic
example is whitebark pine, a species generally limited to high elevation sites, near timberline (a
demarcation where trees no longer grow). Whitebark pine is a slow-growing species that invades
harsh sites and moderates the micro-climatic conditions to allow true firs and spruces to
germinate and grow. The sporadic mixed-intensity fires kill most of the competing trees and some
of the whitebark pines, but some pines survive. Also, burned sites are preferred “cache” sites for
Clark’s nutcrackers, which is the primary means of whitebark pine tree regeneration.36 Other
species that are commonly surface fire or stand-replacement fire species, such as Ponderosa pine
and lodgepole pine, can be mixed-fire-intensity types under certain conditions, typically near the
transition to another area with a different dominant tree species. Ponderosa pine, for example,
may be a mixed-fire-intensity type on relatively moist sites, especially where it mixes naturally
with Douglas fir, such as on north-facing slopes in the northern Rockies. Lodgepole pine may be
a mixed-fire-intensity type on relatively dry sites, where the trees naturally grow farther apart,
such as on the eastern slopes of the Sierra Nevada Mountains.
Less is known about wildfire in mixed-fire-intensity ecosystems, even though they occupy about
24% of U.S. wildlands.37 It is unclear whether fuel loads have accumulated to unnatural levels,
whether crown fires could cause significant ecological damage, or whether fuel reduction
activities would alter wildfire extent or severity in these ecosystems.
Wildfire Effects
The effects of wildfires on natural resources are difficult to assess and are commonly overstated
for two reasons. First, burned areas look bad—blackened trees and ground cover—even following
surface fires. However, many plants recover from being burned. Conifers generally survive even
with as much as 60% of their crowns scorched.38 Other plants, especially grasses, aspen, and
some brush species, resprout vigorously after being burned. Furthermore, animals (regardless of
their size and mobility) are rarely killed by wildfire.39
35 Jon E. Keeley, C. J. Fotheringham, and Marco Marais, “Reexamining Fire Suppression Impacts on Brushland Fire
Regimes,” Science, v. 284 (June 11, 1999), p. 1829.
36 Diana F. Tomback, “Clark’s Nutcracker; Agent of Regeneration,” Whitebark Pine Ecology and Restoration, Diana F.
Tomback, Stephen F. Arno, and Robert E. Keane, eds. (Washington, DC, Island Press, 2001), pp. 90-100.
37 Historical Fire Regimes by Current Condition Classes.
38 See Ross W. Gorte, Fire Effects Appraisal: The Wisconsin DNR Example, Ph.D. dissertation (East Lansing, MI:
Michigan State Univ., June 1981).
39 L. Jack Lyon, Mark H. Huff, Robert G. Hooper, Edmund S. Telfer, David Scott Schreiner, and Jane Kapler Smith,
(continued...)
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The other reason that wildfire effects are commonly overstated is that the reported burned area
includes all the acres within the fire perimeter. However, even severe crown fires are patchy,
leaving some areas lightly burned or unburned. For example, in the Yellowstone fires that were on
the nightly news for weeks in the summer of 1988, 30% of the reported burned area was actually
unburned and another 15%-20% had only surface fire.40 In the 2002 Hayman fire, the worst
wildfire in Colorado history, 35% of the area had a high-severity burn and 16% had a moderate-
severity burn; 34% had a low-severity burn and 15% was unburned.41 Thus, severely burned
acreage is substantially less than the burned area that is reported.
Severe wildfires can cause long-lasting resource damages. Crown fires kill many plants within the
burned area, increasing the potential for erosion until the vegetation recovers. Some observers
have reported “soil glassification,” where the silica in the soils has been melted and fused,
forming an impermeable layer in the soil, although research has yet to document the extent,
frequency, and duration of the condition and the soils and conditions in which it occurs.
Landslides can also occur in areas with unstable soils where the vegetation has burned, such as in
coastal southern California. Timber can also be damaged, although burned trees can often be
salvaged for lumber and other wood products. However, harvesting and processing costs are
typically higher in burned areas, and many object to post-fire salvage harvesting because of its
possible additional impacts on soils and other resource values. Wildfires, especially crown fires,
can also have significant local economic effects—directly on tourism, and indirectly through
effects on timber supply, water quality, and aesthetics. On the other hand, federal wildfire
suppression efforts include substantial expenditures, many of which are made locally, and fire-
fighting jobs are considered financially desirable in many areas.42
Protecting Wildlands and Resources
The federal government is generally responsible for protecting federal lands and their natural
resources from wildfire.43 Wildfire protection of other wildlands and natural resources—state,
local government, and private lands—is the responsibility of the states, although the individual
landowners are responsible for excessive fuel accumulations and other hazardous conditions on
their own lands. As noted above, the FS has a technical and financial assistance program for state
fire agencies.
The principal goal for land and resource protection is to reduce the damages caused by wildfires.
This can best be achieved by reducing burnable biomass (live and dead) to reduce wildfire
intensity and duration, and especially by eliminating the fuel ladders (relatively continuous
(...continued)
Wildland Fire in Ecosystems: Effects of Fire on Fauna, Gen. Tech. Rept. RMRS-GTR-42-vol. 1 (Ogden, UT: USDA
Forest Service, Rocky Mountain Research Station, Jan. 2000).
40 Lyon, et al., Effects of Fire on Fauna, p. 44.
41 Robichaud et al., “Postfire Rehabilitation of the Hayman Fire,” p. 294.
42 Nelson, A Burning Issue, pp. 37-38.
43 The federal government also protects some state and private lands where the landowner has a cooperative agreement
with a federal agency, while some federal lands similarly are protected by state or private organizations under
cooperative agreements.
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biomass from the surface to tree crowns) that facilitate wildfire transition from a surface fire to a
crown fire.44 Fuel treatments can also reduce the crown bulk density (the biomass, especially fine
fuels, in the tree crowns), making it more difficult for a crown fire to sustain itself, thus making a
wildfire more controllable.45 Reducing burnable biomass, however, does not eliminate wildfires,
because fuel reduction does not directly alter the dryness of the biomass or the probability of an
ignition.
The two principal mechanisms for reducing fuels are prescribed burning and mechanical
treatments, although the two tools can also be combined. Each tool has benefits, costs, and risks
or limitations to its use.
Prescribed Burning
Prescribed burning is intentionally setting fires in specified areas when fuel and weather
conditions are within prescribed limits (e.g., fuel moisture content, relative humidity, wind
speed). Some observers include, in their definition of prescribed burning, naturally occurring fires
that are allowed to burn because they are within acceptable areas and conditions, as identified in
fire management plans. The agencies term such fires wildland fire use, and do not identify them
as prescribed fires, but do include the acres burned in wildland-fire-use fires as acres treated for
fuel reduction.
Prescribed burning is used for reducing biomass fuels because it is the only means available for
eliminating fine fuels (grasses, needles, leaves, forbs, and twigs and shrubs less than a quarter-
inch in diameter [pencil-sized]). Burning converts the vegetation to smoke (carbon dioxide, water
vapor, fine particulates, and other pollutants) and ashes (mineralized forms of the organic matter,
readily available for absorption by new plant growth). Reducing fine fuels is critical in wildfire
protection and control, because fine fuels are necessary to carry wildfires; without fine fuels,
wildfires cannot spread.
Prescribed burning has various limitations. Smoke can be a problem, contributing to human
health problems, especially in areas where inversions are common or with relatively stagnant
airsheds. Also, prescribed burning is risky. It is not controlled burning; there is no such thing as
controlled burning, because there is no switch to turn the fire off. Prescribed fire is also an
indiscriminate tool for reducing tree density, crown density, and fuel ladders, burning what is
available, depending on a host of site-specific and micro-climatic conditions.
Finally, prescribed burning is expensive. Actually starting the prescribed fire is cheap—matches
don’t cost a lot. However, minimizing the risk to surrounding areas (especially private lands and
housing developments) requires planning and preparation as well as sufficient trained personnel
and supervisors to react when unexpected fire behavior occurs or weather conditions change.
Prescribed burning costs are estimated to range from $12 to $174 per acre, depending on the fuel
type, treatment method, size of area to be treated, steepness of slopes, site elevation, and other
44 Russell T. Graham, Alan E. Harvey, Theresa B. Jain, and Jonalea R. Tonn, The Effects of Thinning and Similar Stand
Treatments on Fire Behavior in Western Forests, Gen. Tech. Rept. PNW-GTR-463 (Portland, OR: USDA Forest
Service, Pacific Northwest Research Station, 1999).
45 Graham et al., The Effects of Thinning on Fire Behavior.
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factors.46 A prescribed fire that becomes a wildfire, such as the Cerro Grande fire in Los Alamos,
NM (which burned 239 houses in town), raises questions about the practice and about the fire
managers who use it. Thus, fire managers tend to err on the side of excessive personnel (and cost)
for a prescribed fire, rather than risk a costly, damaging wildfire with far higher costs.
Mechanical Treatment
Mechanical fuel treatment includes a wide array of activities designed to reduce biomass on a
site. Foresters have a variety of terms for the various activities, including:47
• pruning—removing lower tree branches, which eliminates fuel ladders and can
reduce crown density.
• release—removing several to many trees from a young stand (saplings or
smaller) to concentrate wood growth on desirable trees, which reduces crown
density.
• thinning—removing a portion of the standing trees; the portion can vary widely
from very light (relatively few trees) to very heavy (more than half the trees in
the stand). Thinning can be commercial (if the trees are large enough for
products) or precommercial. It can be used to eliminate fuel ladders and reduce
crown density, depending on the approach and portion of trees removed.
Thinning approaches include:
—low thinning, or thinning from below, to remove the smallest and poorest
specimens, which eliminates fuel ladders and can reduce crown density;
—crown thinning, or thinning from above, to open the canopy to stimulate growth
on the remaining trees, which substantially reduces crown density;
—selection thinning, to remove the least desirable trees for the future stand, which
reduces crown density and can eliminate fuel ladders; and
—mechanical thinning, to provide appropriate spacing for the remaining trees,
which reduces crown density and can eliminate fuel ladders.
• salvage harvesting—removing a portion to all of the standing trees, many of
which have been killed or are in imminent danger. This includes presalvage
harvesting (removing highly vulnerable trees before they are killed) and
sanitation harvesting (removing trees to control the spread of insects or diseases).
It reduces (or eliminates) crown bulk density, and might reduce fuel ladders.
46 U.S. Forest Service, Fuels Planning: Science Synthesis and Integration—Economic Uses Fact Sheet: 8—Prescribed
Fire Costs, December 2004, http://www.fs.fed.us/rm/pubs/rmrs_rn020_08.pdf.
47 For more information, see David M. Smith, Bruce C. Larson, Matthew J. Kelty, and Mark S. Ashton, The Practice of
Silviculture: Applied Forest Ecology, 9th ed. (New York, NY: John Wiley & Sons, 1997).
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Treatment Choices
Mechanical fuel treatment clearly involves choices—about the amount of biomass to be removed,
and about the nature of the biomass to be removed (small and weak trees, lower limbs, vulnerable
trees or species, etc.). The choice can also be over the method used for the treatment: a
commercial sale, if the treatment yields commercially usable wood; a stewardship contract, if
commercially usable wood can be exchanged for other activities; a service contract, for specified
actions; an end-results contract, to specify what is left after treatment; or even treatment by
agency personnel. All of these choices affect public acceptance of the proposed treatment.
Benefits and Limitations
The primary benefit of mechanical fuel treatment is the high degree of control over the results.
One report stated:48
Mechanical thinning has the ability to more precisely create targeted stand structure than does
prescribed fire.... Used alone, mechanical thinning, especially emphasizing the smaller trees and
shrubs, can be effective in reducing the vertical fuel continuity that fosters initiation of crown
fires. In addition, thinning of small material and pruning branches are more precise methods than
prescribed fire for targeting ladder fuels and specific fuel components.
The authors also observed some of the limitations of mechanical fuel treatment:49
However, by itself mechanical thinning does little to beneficially affect surface fuels with the
exception of possibly compacting, crushing, or masticating it during the thinning process.
Depending on how it is accomplished, mechanical thinning may add to surface fuels (and
increase surface fire intensity) unless the fine fuels that result from the thinning are removed from
the stand or otherwise treated....
Thinning and prescribed fires can modify understory microclimate that was previously buffered
by overstory vegetation.... Thinned stands (open tree canopies) allow solar radiation to penetrate
to the forest floor, which then increases surface temperatures, decreases fire fuel moisture, and
decreases relative humidity compared to unthinned stands—conditions that can increase surface
fire intensity.... An increase in surface fire intensity may increase the likelihood that overstory
tree crowns ignite.
Other sources have similarly reported the limitations of thinning:50
Depending on the forest type and its structure, thinning has both positive and negative impacts on
crown fire potential. Crown bulk density, surface fuel , and crown base height [fuel ladders] are
primary stand characteristics that determine crown fire potential. Thinning from below, free
thinning, and reserve tree shelterwoods have the greatest opportunity for reducing the risk of
crown fire behavior. Selection thinning and crown thinning that maintain multiple crown layers ...
48 Russell T. Graham, Sarah McCaffery, and Theresa N. Jain, tech. eds., Science Basis for Changing Forest Structure to
Modify Wildfire Behavior and Severity, Gen. Tech. Rept. RMRS-GTR-120 (Ft. Collins, CO: USDA Forest Service,
Rocky Mountain Research Station, Apr. 2004), p. 25.
49 Graham, et al., Science Basis for Changing Forest Structure, pp. 25, 27.
50 Graham, et al., The Effects of Thinning on Fire Behavior, abstract.
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will not reduce the risk of crown fires except in the driest ponderosa pine ... forests. Moreover,
unless the surface fuels created by using these treatments are themselves treated, intense surface
wildfire may result, likely negating positive effects of reducing crown fire potential. No single
thinning approach can be applied to reduce the risk of wildfires in the multiple forest types of the
West.
Thus, thinning and pruning have the potential to reduce the risk of crown fire, but may increase
wildfire risk until the slash (non-commercial biomass) degrades (rots or burns, typically in a few
years to decades, depending on the ecosystem), or is removed. In addition, thinning is an
expensive proposition, with treatment costs ranging “from $35 to over $1000 per acre depending
on the type of operation, terrain, and number of trees to be treated.”51
Commercial operations—commercial thinning, stewardship contracting, and salvage logging—
have been suggested as a means to moderate the high cost of mechanical fuel treatment. However,
commercial timber sales on federal lands commonly cost more to prepare and administer than
they return to the Treasury.52 The results of commercial operations for fuel reduction are also
questionable:53
The proposal that commercial logging can reduce the incidence of canopy fires was untested in
the scientific literature. Commercial logging focuses on large diameter trees and does not address
crown base height—the branches, seedlings and saplings which contribute so significantly to the
“ladder effect” in wildfire behavior.
Others have also noted the likely net cost of thinning to reduce the risk of crown fires:54
Although large trees can be removed for valuable products, the market value for the smaller logs
may be less than the harvest and hauling charges, resulting in a net cost for thinning operations.
However, the failure to remove these small logs results in the retention of ladder fuels that
support crown fires with destructive impacts to the forest landscape. A cost/benefit analysis
broadened to include market and nonmarket considerations indicates that the negative impacts of
crown fires are underestimated and that the benefits of government investments in fuel reductions
are substantial.
Combined Operations
The ability to control the resulting stand structure with mechanical treatments and the ability to
remove fine fuels with prescribed burning make combining the two treatments seem a logical
51 A Strategic Assessment of Forest Biomass and Fuel Reduction Treatment in Western States, Gen. Tech. Rept.
RMRS-GTR-149 (Ft. Collins, CO: USDA Forest Service, Rocky Mountain Research Station, 2005).
52 CRS Report RL32485, Below-Cost Timber Sales: An Overview, by Ross W. Gorte.
53 Henry Carey and Martha Schumann, Modifying WildFire Behavior—The Effectiveness of Fuel Treatments: The
Status of Our Knowledge, Southwest Region Working Paper 2 (Santa Fe, NM: National Community Forestry Center,
April 2003), pp. i-ii.
54 C. Larry Mason, Bruce R. Lippke, Kevin W. Zobrist, Thomas D. Bloxton, Jr., Kevin R. Cedar, Jeffrey M. Comnick,
James B. McCarter, and Heather K. Rogers, “Investments in Fuel Removal to Avoid Forest Fires Result in Substantial
Benefits,” Journal of Forestry, v. 104 (Jan./Feb. 2006): p. 27.
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choice. However, empirical evidence to document the effectiveness of such combined operations
is limited:55
A more limited number of studies addressed the effectiveness of a combination of thinning and
burning in moderating wildfire behavior. The impacts varied, depending on the treatment of the
thinning slash prior to burning.
In addition, the cost of combined operations is substantially greater than the cost of either alone.
Area Needing Treatment
The areas that might benefit from prescribed burning and/or mechanical treatment are not entirely
clear. Table 1, below, shows the acreage of national forest land, Department of the Interior land,
and all other land by (a) historical fire regime (comparable to the ecosystem types described
above); and (b) condition class—low risk (Class 1), moderate risk (Class 2), and high risk (Class
3) of losing key ecosystem components in a wildfire.
Based on the discussion above of the effectiveness of various treatments, it seems reasonable to
conclude that treating lands in the Class 3 (high risk), low severity (surface fire) regime could
reduce the likelihood of crown fires in these ecosystems, where such fires are unnatural (or at
least very rare). Table 1 shows this to include 28.8 million acres of national forest land, 6.5
million acres of Interior land, and 42.2 million acres of other federal, state, and private land.
Table 1. Lands at Risk of Ecological Damage from Wildfire,
by Landowner Group and Historical Fire Regime
(in millions of acres)
Class 1
Class 2
Class 3
Landowner/Historical Fire Regime
Total
(low risk)
(mod. risk)
(high risk)
USDA Forest Service
Low severity (surface fire)
83.67
19.87
34.96
28.83
Mixed
severity
53.93 16.05 26.71 11.17
Stand
replacement
58.93 29.03 18.77 11.13
Forest
Service,
total
196.52 64.95 80.45 51.12
Dept. of the Interior
Low severity (surface fire)
49.00
18.70
23.83
6.46
Mixed
severity
97.80 62.05 25.82 9.92
Stand
replacement
80.93 47.67 26.17 7.09
Interior Dept., total
227.72
128.42
75.83
23.47
Other federal, state, and private lands
Low severity (surface fire)
296.02
136.46
117.37
42.20
55 Carey and Schumann, Modifying WildFire Behavior, pp. i-ii.
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Class 1
Class 2
Class 3
Landowner/Historical Fire Regime
Total
(low risk)
(mod. risk)
(high risk)
Mixed
severity
142.18 49.55 59.72 32.92
Stand
replacement
386.81 217.46 137.28 32.07
Other
lands,
total
825.01 404.60 313.24 107.18
Source: Kirsten M. Schmidt, James P. Menakis, Colin C. Hardy, Wendel J. Hann, and David L. Bunnell,
Development of Coarse-Scale Spatial Data for Wildland Fire and Fuel Management, Gen. Tech. Rept. RMRS-87 (Ft.
Col ins, CO: USDA Forest Service, Rocky Mountain Research Station, Apr. 2002), pp. 13-15.
The cost to treat these lands varies widely. One study, cited above, reported mechanical treatment
costs of $35 to $1,000 per acre, depending on terrain, type of operation, and number of trees to be
cut.56 Others have similarly reported highly variable costs for commercial mechanical treatment
above and below the “base case” cost of $150 per acre, depending on tree size, stand density,
terrain, and whether the treatment was conducted in the wildland-urban interface.57 The same
source reported similar variability in costs for prescribed burning, above and below the “base
case” cost of $105 per acre. Federal appropriations for fuel treatment averaged about $170 per
acre for FY2001-FY2006—$165 per acre for the Forest Service and $174 per acre for the BLM.58
The General Accounting Office (GAO, now the Government Accountability Office) used a Forest
Service estimate of $300 per acre in its 1999 estimate of needed funding for fuel treatment,
because of the higher cost per acre to treat additional western lands.59 At $300 per acre, Forest
Service costs to treat the Class 3 surface fire regime lands would be $8.6 billion, and Department
of the Interior costs would be $1.9 billion. Other surface (low severity) fire regime lands might
also warrant treatment, although the lower risk of ecological damage suggests a lower priority for
treatment.
It is unclear whether any lands other than the surface fire regime lands warrant fuel treatment.
The existing research evidence on fuel treatment for stand-replacement fire regimes raises
questions about the effectiveness of both mechanical treatment and prescribed fire for reducing
the likelihood of damages from a crown fire. One might even question whether ecological
damage can be ascribed to a crown fire in a stand-replacement fire ecosystem, since these
ecosystems have evolved adaptations to reestablish themselves following crown fires. Evidence is
also lacking about the effectiveness of mechanical treatments and prescribed burning on mixed-
intensity fire ecosystems. Thus, it is not certain whether fuel treatment on these mixed-intensity
fire regime lands and stand-replacement fire regime lands would provide any significant wildfire
protection.
56 A Strategic Assessment of Forest Biomass.
57 Roger D. Fight and R. James Barbour, Financial Analysis of Fuel Treatments, Gen. Tech. Rept. PNW-GTR-662
(Portland, OR: USDA Forest Service, Pacific Northwest Research Station, Dec. 2005).
58 Data from annual agency budget justifications, presented in CRS Report RL33990, Federal Funding for Wildfire
Control and Management, by Ross W. Gorte and Kelsi Bracmort.
59 GAO, Western National Forests: A Cohesive Strategy Is Needed to Address Catastrophic Wildfire Threats,
GAO/RCED-99-65 (Washington, DC: April 1999). The Forest Service has done more fuel treatment in the South,
where the generally gentler terrains, denser and more uniform timber stands, and historic fire patterns have kept
treatment costs per acre lower than in the West.
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Delays and Changes in Federal Decision-Making
Some advocates of fuel treatment are concerned that delays and changes to the implementation of
fuel treatments might lead to catastrophic crown fires that could have been prevented by more
expeditious fuel treatment. Concerns are generally linked to consultations under the Endangered
Species Act (ESA, P.L. 93-205; 16 U.S.C. §§1531-1544), and to public involvement under the
National Environmental Policy Act of 1969 (NEPA; P.L. 91-190, 42 U.S.C. §§4321-4347) and the
Forest Service Appeals Reform Act (ARA; §322 of P.L. 102-381, the FY1993 Interior
Appropriations Act, 16 U.S.C. §1612 note).60
Involving the public and consulting over possible impacts on endangered or threatened species
take time, and concerns and objections can delay, modify, or even prevent some proposed actions.
However, others caution that expedited review or limits on ESA consultation and on public
oversight of proposed fuel treatments may allow treatments to include commercial timber
harvests or other actions that provide little wildfire protection and exacerbate fuel accumulations
in the short run, while causing other environmental damages.
This raises the question of the effect of delays on wildfire threats. Clearly, structures in the
wildland-urban interface are threatened by wildfire, but as shown above, fuel treatment provides
little, if any, fire protection for structures, and thus delaying fuel treatments has little consequence
for structure protection. Resources in surface fire ecosystems with unnatural fuel accumulations
are at risk from severe wildfires. The odds of having treated the “right” acres to prevent a crown
fire with significant resource damages are, however, quite low. For the past decade, during which
more area burned than in any other decade since 1960, wildfires have burned an average of 7.0
million acres annually. Total wildlands in the United States are 1.45 billion acres—roughly 640
million acres of federal land,61 and roughly 815 million acres of private forest and rangeland.62
Thus, the likelihood of any particular acre burning in any given year, on average, is less than
0.66% (i.e., burning once every 150 years). Obviously, the risk for certain areas in particular
years can be much higher—5.4% of Idaho’s wildlands burned in 2007, for example—but this is
offset by much lower risks for those areas in other years and for other areas in the same year—
0.2% of Idaho’s wildlands burned in 2002, while 0.04% of Colorado wildlands burned in 2007, in
contrast to 1.8% in 2002, when the Hayman fire burned.63 Wildfire risk is probably somewhat
higher in western states than the national average, because the ecosystems in the Lake States,
mid-Atlantic region, and New England experience less fire; however, even if the risk were 50%
greater than the national average (which seems unlikely because the larger area in the West
already contributes to a higher national average), the risk would still be less than 1% per year.
In addition to the low probability of a particular acre burning is the modest likelihood of an area
being treated. The Forest Service and BLM treated 2.7 million acres of their lands annually from
60 See CRS Report RL32436, Public Participation in the Management of Forest Service and Bureau of Land
Management Lands: Overview and Recent Changes, by Pamela Baldwin.
61 See CRS Report R42346, Federal Land Ownership: Overview and Data, by Ross W. Gorte et al.
62 Includes acres of private forests and rangelands in the coterminous 48 states. U.S. Dept. of Agriculture, Natural
Resources Conservation Service, Summary Report 2007 National Resources Inventory, December 2009, p. 6.
63 See CRS memoranda on Wildfire and Wildland Data, by Ross W. Gorte, June 20, 2003, and March 3, 2008,
available from the author.
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FY2003 through FY2007.64 This is less than 8% of their Class 3 surface fire ecosystem lands, and
less than 3% of Class 3 plus Class 2 surface fire ecosystem lands. If the same acreage of
treatments are spread more broadly—to Class 1 surface fire ecosystem lands or to lands in other
fire regimes—the probability of treating a particular acre to prevent a crown fire diminishes
further.
Nonetheless, lengthy delays can exacerbate the risks. Annual probabilities of a wildfire burning
an area and of an area being treated are both cumulative. Over a 10-year period, the likelihood of
an area burning is more than 6%, while the likelihood of a moderate- or high-risk surface fire
ecosystem being treated rises to 15% (if half of all treatments are concentrated on these lands).
Thus, relatively brief delays may have relatively little impact of the likelihood of an area being
burned in an unnatural crown fire, but longer delays (a decade or more) could have a significant
impact.
ESA Consultations65
The ESA established a process for federal agencies to consult with the Fish and Wildlife Service
(FWS), or with the National Marine Fisheries Service (NMFS) for some species, on any actions
that might jeopardize a listed endangered or threatened species or adversely modify its critical
habitat. This is not a problem for firefighting, as immediate, informal consultations can occur
during an emergency, with formal consultation to follow after the emergency has passed.
However, some fuel treatments might jeopardize a species or adversely modify its habitat, which
would require ESA consultation. Consultation means the FWS (or NMFS) would review the
proposed action and, if jeopardy or adverse habitat impacts are likely, propose a “reasonable and
prudent alternative” to achieve the same purpose without jeopardy or adverse habitat
modification. The vast majority of agency activities have a finding of no jeopardy, and most with
jeopardy have a reasonable and prudent alternative; actions with jeopardy and no alternative
findings are exceedingly rare.
Fuel treatments that reduce the likelihood of crown fires in ecosystems where such fires were
historically rare are generally unlikely to jeopardize or adversely modify the critical habitat of
endangered species. Many species in North America are adapted to survive and even thrive with
natural wildfires. One study reported that more than 90% of rare, threatened, and endangered
plants in the 48 coterminous states either benefit from fire or are found in fire-adapted
ecosystems.66 Also, as noted above, animal mortality in wildfires is rare. Thus, treatments that
only restore forests to conditions that allow a historically natural ecological role for wildfire are
more likely to benefit endangered and threatened species than to harm them.
64 See Table 6 in CRS Report RL33990, Federal Funding for Wildfire Control and Management, by Ross W. Gorte and
Kelsi Bracmort. The agencies no longer report fuel treatment on the same basis, and thus actual treatments since
FY2007 are not analyzed.
65 For information on ESA generally, see CRS Report RL31654, The Endangered Species Act: A Primer, by M. Lynne
Corn, Kristina Alexander, and Eugene H. Buck.
66 Amy Hessl and Susan Spackman, Effects of Fire on Threatened and Endangered Plants: An Annotated Bibliography,
Information and Technical Report 2 (Ft. Collins, CO: U.S. Dept. of the Interior, National Biological Service, n.d.).
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Nonetheless, ESA consultations take time, and can delay fuel treatments. This is more likely to be
the case when restoration treatments (e.g., prescribed burning or thinning from below) are
combined with other activities (e.g., commercial timber harvesting), such as in a stewardship
contract. Thus, the method used to undertake the treatment, as well as the nature of the treatment
itself, determines the length of delays and possible project modifications from ESA consultations.
NEPA Environmental Analysis and Public Involvement67
NEPA requires federal agencies to review the environmental effects of “major Federal actions
significantly affecting the quality of the human environment.” Agencies must consider every
significant aspect of the environmental impacts of a proposed action before making an
irreversible commitment of resources to the project. NEPA also requires that agencies inform the
public that they have considered those impacts in their decision-making process. In his executive
order on NEPA implementation, President Richard Nixon directed the agencies to go beyond just
informing the public, to actively involve the public early in the decision-making process.68 Fuel
reduction treatments to protect resources from wildfires are generally considered to be major
federal actions subject to NEPA.
Environmental Analysis
The action agency must analyze the possible environmental consequences of its actions. The first
step is to determine if the action will have significant environmental impacts. There are three
possible outcomes. If significant impacts are likely, then the agency prepares an environmental
impact statement (EIS). If the impacts are normally insignificant—individually and
cumulatively—the activity can be categorically excluded from further NEPA environmental
analysis and public involvement. (See below.) If the significance of the impacts is uncertain, the
agency prepares an environmental assessment (EA) to determine the significance of the impacts.
The EA leads either to a finding of no significant impact (FONSI) or to an EIS.
Advocates of expedited fuel treatment are concerned about the time needed to prepare an EIS or
even an EA. Information collection and analysis may take from several days to a few months,
depending on the magnitude and complexity of the proposed action. An EIS involves additional
steps to assess the likely and the possible environmental impacts and to inform and involve the
public. These steps include scoping (public discussions about the nature, location, and possible
consequences of the proposal); a draft EIS, examining a range of alternatives and generally
identifying a preferred alternative; public comments on the draft and the preferred alternative; and
then a final EIS and record of decision (ROD).69 Only after completing this process—which can
take a year or more for large, complex projects—can the agency undertake the action. Thus,
67 For more information on NEPA generally, see CRS Report RL33152, The National Environmental Policy Act
(NEPA): Background and Implementation, by Linda Luther, and CRS Report RS20621, Overview of National
Environmental Policy Act (NEPA) Requirements, by Kristina Alexander.
68 Executive Order 11514, “Protection and Enhancement of Environmental Quality,” 35 Fed. Reg. 4247 (March 5,
1970).
69 A simplified flowchart of this process can be found in CRS Report RL33152, The National Environmental Policy Act
(NEPA): Background and Implementation, by Linda Luther.
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proponents of expeditious fuel reduction projects often advocate various approaches to accelerate
the process, discussed below.
Categorical Exclusions (CEs)
As noted above, certain projects can be categorically excluded from the requirement to prepare an
EA or an EIS. Such a CE action is defined as:70
a category of actions which do not individually or cumulatively have a significant effect on the
human environment ... and for which, therefore, neither an environmental assessment nor an
environmental impact statement is required.... Any procedures under this section shall provide for
extraordinary circumstances in which a normally excluded action may have a significant
environmental effect.
CEs are typically used for relatively minor, routine actions (e.g., thinning, debris removal) that
the agency does frequently and has found to have at most insignificant environmental impacts.
For projects approved under CEs, the Forest Service is not required to provide notice and
opportunity for public comment as otherwise required for agency activities under the ARA. (See
below.)
In certain situations—such as those involving controversial issues (e.g., wetlands and roadless
areas) or specifically protected resources (e.g., endangered species and archaeological sites)—
known as extraordinary circumstances, CEs cannot be used. In 2002, the Forest Service modified
its application of extraordinary circumstances, allowing the responsible official to determine
whether the extraordinary circumstances warranted an EA or an EIS, rather than automatically
precluding use of a CE in the presence of extraordinary circumstances.71
The Forest Service has identified numerous categories of actions for which a CE may be used;
two relate directly to wildfire protection (for details on Forest Service CEs and extraordinary
circumstances, see the Appendix):72
6. Timber stand and/or wildlife habitat improvement activities ..., [including] thinning or brush
control to improve growth or reduce fire hazard ..., prescribed burning to control understory
hardwoods in stands of southern pine, [and] prescribed burning to reduce natural fuel build-up....
10. Hazardous fuel reduction activities using prescribed fire, not to exceed 4,500 acres, and
mechanical methods for crushing, piling, thinning, pruning, cutting, chipping, mulching, and
mowing, not to exceed 1,000 acres ... limited to ... the wildland-urban interface; or Condition
Classes 2 or 3 [moderate or high risk of ecological damage] in Fire Regimes I, II, or III [surface
fire, stand-replacement fire with a return interval of 35 years or less, and mixed-intensity fire].
(emphasis in original)
70 40 C.F.R. §1508.4.
71 67 Fed. Reg. 54622 (Aug. 23, 2002).
72 Forest Service Handbook, National Headquarters (WO), Washington, DC, FSH 1909.15—Environmental Policy and
Procedures Handbook. Chapter 30—Categorical Exclusion from Documentation, Amendment No. 1909.15-2007-1
(Feb. 15, 2007).
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Forest Service use of the latter CE was halted after a court found it was arbitrary and capricious.73
Other CEs have also been challenged, raising questions about the availability of CEs for fuel
reduction projects.74
Forest Service Appeals Reform Act
In addition to public involvement under NEPA, the Forest Service must also inform the public of
its decisions and provide an opportunity for the public to request an administrative review of its
decisions under the Forest Service Decisionmaking and Appeals Reform Act (ARA).75
Subsections (a) and (b) require the Forest Service to provide notice and an opportunity for public
comment on proposed actions; this is the only provision requiring notice and comment on Forest
Service proposals other than under NEPA. Subsections (c) and (d) specify an administrative
appeals process—review by a higher-ranking official—for those who had commented on the
proposal and object to the decision.
GAO was asked to examine administrative appeals of fuel reduction projects.76 For FY2001 and
FY2002, prior to promulgation of the hazardous fuel reduction CE, 59% of fuel reduction projects
used CEs and could not be appealed. Of those that could be appealed, 58% were appealed (i.e.,
24% of all fuel reduction projects during that period). Of those, 73% were implemented without
change, 8% were modified, and 19% (less than 5% of all projects) were withdrawn or reversed.
Furthermore, 79% of the appeals were resolved within the prescribed 90 days. These data are
supported by a study of all Forest Service administrative appeals.77 This study found that 8% of
appeals were granted (i.e., decision reversed) and that 9% of appealed decisions were withdrawn.
A different study examined factors that increased the likelihood of a fuel reduction project being
appealed.78 It reported that appeals were more likely for fuel reduction projects that (1) affected
more area; (2) included more activities for the site; (3) included commercial timber harvest; (4)
included as a purpose reducing fuels generated by the project; and (5) had at least one threatened
or endangered mammal near the site. These factors are indirectly confirmed in the GAO study,
since 92% of projects with EISs (larger projects with likely environmental impacts) were
appealed, compared to 52% of projects with EAs (projects with uncertain environmental
impacts).79 Conversely, projects were significantly less likely to be appealed if the project was (1)
73 Sierra Club v. Bosworth, 510 F. 3d 1016 (9th Cir. 2007).
74 For information on the status of relevant judicial decisions, see CRS Report R40237, Federal Lands Managed by the
Bureau of Land Management (BLM) and the Forest Service (FS): Issues in the 111th Congress, coordinated by Ross W.
Gorte and Carol Hardy Vincent.
75 Section 322 of the Department of the Interior and Related Agencies Appropriations Act, 1993 (P.L. 102-381; 16
U.S.C. §1612 note). The appeals process under the ARA, including the public notice and comment period, will change
to a pre-decisional objection process as soon as final regulations are issued (P.L. 112-74 §428). The law does not
establish a time frame for issuing the regulations.
76 GAO, Forest Service: Information on Appeals and Litigation Involving Fuels Reduction Activities, GAO-04-52
(Washington, DC, Oct. 2003).
77 Gretchen M. R. Teich, Jacqueline Vaughn, and Hanna J. Cortner, “National Trends in the Use of Forest Service
Administrative Appeals,” Journal of Forestry, vol. 102 (March 2004): pp. 14-19.
78 David N. LaBand, Armando González-Cabán, and Anwar Hussain, “Factors That Influence Administrative Appeals
of Proposed USDA Forest Service Fuels Reduction Actions,” Forest Science, vol. 52, no. 2 (2006): pp. 477-488.
79 GAO, Information on Appeals of Fuel Reduction Activities.
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implemented by Forest Service personnel or a service contract; and (2) in the wildland-urban
interface.
These data suggest that administrative appeals are less of a problem than the advocates of fuel
treatment suggest. Only about a quarter of proposed projects are appealed, with less than 5%
prevented from being implemented, and delays of less than 90 days for most projects. However,
for prescribed burning, a 90-day delay can be significant, since the period within the prescribed
conditions can be brief.
Expedited Procedures
Proponents of aggressive fuel treatment continue to be concerned about delays from the ESA,
NEPA, and ARA review processes, and have pressed for various means for accelerating the
reviews. Some procedures are currently feasible under existing regulations, others have been
enacted by Congress in various contexts, and more have been proposed.
Expedited ESA Consultations
As noted above, during emergencies, the agencies can consult informally for rapid action, with
formal consultations to follow when the situation has stabilized. This clearly applied during
wildfire suppression activities, but fuel reduction treatments are not emergency actions that
require an immediate response to prevent damages. As discussed above, lengthy (multi-year)
delays in fuel reduction activities can increase the likelihood of resource damages from wildfires,
but brief delays have minor impacts.
The agencies have developed an alternative approach to ESA consultations that is intended to
accelerate the ESA review process: counterpart regulations.80 These regulations allow the Forest
Service, BLM, and others to assess whether the proposed fuel reduction action is likely to
jeopardize a listed threatened or endangered species or to adversely modify critical habitat, rather
than to consult with the Fish and Wildfire Service on the likelihood of jeopardy or adverse habitat
modification. While some ESA counterpart regulations have been challenged successfully, the
counterpart regulations related to wildfire management remain in place.81
Expedited NEPA Reviews (Other than Through CEs)
In addition to the option of CEs, the NEPA regulations of the Council on Environmental Quality
(CEQ) allow for alternative arrangements in the event of an emergency.82 These alternative
arrangements do not waive NEPA requirements, but establish an alternative means of fulfilling
those requirements for actions necessary to control the immediate impacts of an emergency,
typically with conditions on short-term and long-term actions.83 For example, in 1998, the Forest
80 68 Fed. Reg. 68254 (Dec. 8, 2003).
81 See CRS Report RL33779, The Endangered Species Act (ESA) in the 110th Congress: Conflicting Values and
Difficult Choices, by Eugene H. Buck et al.
82 40 C.F.R. §1506.11.
83 See CRS Report RL33104, NEPA and Hurricane Response, Recovery, and Rebuilding Efforts, by Linda Luther.
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Service requested alternative arrangements for rapid restoration actions following a windstorm
that damaged 103,000 acres of national forest land in Texas that contained critical habitat for the
endangered red-cockaded woodpecker; CEQ concurred that the situation was an emergency and
agreed to alternative arrangements that included subsequent preparation of an EA, limits on tree
removal, long-term public involvement, emergency consultation under ESA, and more.
For fuel treatment, NEPA alternative arrangements will rarely provide a means of accelerated
action. First, alternative arrangements are not used very often—42 requests were made from 1980
through 2010.84 Second, alternative arrangements are to be used for emergencies. Fuel conditions
in a delineated area might occasionally be an emergency, such as in the wake of a ice storm or a
tornado, but fuel levels generally do not constitute an emergency requiring immediate action.
Healthy Forests Restoration Act
The Healthy Forests Restoration Act of 2003 (HFRA; P.L. 108-148, 16 U.S.C. §§6501-6591)
expedited review processes in several ways. In Title I, it modifies the NEPA environmental
analysis and public involvement processes for authorized Forest Service and BLM fuel reduction
projects (based on priorities, exclusions, and other standards in the act). The EA or EIS for each
project may be limited to the proposed action, the no-action alternative, and possibly an
additional alternative (in contrast to the range of alternatives normally required). The agencies
“shall facilitate collaboration” with tribes and state and local governments and “participation” of
interested persons; however, the law does not explain the distinction between collaboration with
certain interests and participation by other interests.
Title I includes two other changes to accelerate fuel reduction projects. First, for the Forest
Service, it replaces ARA administrative appeals with a “predecisional administrative review
process.” This process is only available to persons who submitted “specific written comments that
relate to the proposed action” during scoping or the public comment period on the draft NEPA
document. The process is also limited to the period between completing the EA or EIS and
issuing the record of decision, with no requirements for how long that period must be. Then, the
act restricts judicial review, generally limiting plaintiffs to those who have exhausted
administrative review processes and specifying the venue for review, while encouraging
expeditious judicial review and requiring the courts to balance the short- and long-term effects of
action and inaction in deciding on injunctions.
In Title IV, HFRA allows the use of CEs for “applied silvicultural assessments”—timber
harvesting and other vegetative treatments “for information gathering and research purposes.”
Each treatment is limited to 1,000 acres, with exclusions for certain areas and limitations on the
adjacency of treatments, and with public notice and comment and “peer reviewed by scientific
experts selected by the Secretary [of Agriculture or of the Interior], which shall include non-
Federal experts.” Total acreage of all applied silvicultural assessments using this CE is limited to
250,000 acres.
84 Council on Environmental Quality, “Alternative Arrangements” website, http://ceq.hss.doe.gov/nepa_information/
alternative_arrangements.html.
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Other Possibilities
Congress can create other means of accelerating the decision-making process for fuel reduction
treatments. Congress has exempted certain federal activities (such as construction of the Trans-
Alaska Pipeline to deliver oil from the North Slope) from NEPA compliance.85 Congress has also
directed in law that no EIS or EA be prepared in certain instances, through direct statutory
language or by deeming that the authorized activities are not major federal actions that
significantly affect the human environment. Congress has also pronounced certain analyses or
substitute processes to be sufficient or adequate under NEPA.
Congress has also established alternative review processes. Typically this is in addition to NEPA
public involvement, to accelerate the review by obtaining broader, organized review early in the
decision-making process, vetting the decision before public review. Examples include resource
advisory committees (RACs) under Section 403 of the Federal Land Policy and Management Act
of 1976 (FLPMA; P.L. 94-579, 43 U.S.C. §1753) and under Title II of the Secure Rural Schools
and Community Self-Determination Act of 2000 (P.L. 106-393; 16 U.S.C. §500 note). Other
advisory or collaborative groups have been established or acknowledged statutorily, commonly to
provide supplemental public involvement.
Considerations in Expediting Decisions
Public acceptance of options to accelerate fuel treatments depends on a variety of factors. In
general, earlier discourse among interests about the risks and needed treatments lead to greater
comfort with the resulting decisions. One study found that survey respondents were willing to
accept limitations on the rights to appeal and litigate agency decisions, but wanted to be more
informed and involved in those decisions.86 Greater specificity in approved treatments also is
likely to result in greater acceptance. For example, a treatment prescription that specifies
“thinning from below to approximately 20-foot spacing of remaining trees and emphasizing
retention of Ponderosa pine” is likely to be more acceptable than “mechanical treatment to reduce
stand density.” Finally, authors have identified the need for collective action to minimize conflict
over decisions, and three broad social factors to achieve collective action: developing
collaborative capacity, framing problems in mutually understood terms, and creating mutual trust
among groups.87 These are factors that take time, and cannot be legislated directly, although
Congress can foster (or negate) their development by the ways in which it authorizes agency
action to promote wildfire protection.
85 See CRS Report 98-417, Statutory Modifications of the Application of NEPA, by Pamela Baldwin.
86 David M. Ostergren, Kimberly A. Lowe, Jesse B. Abrams, and Elizabeth J. Ruther, “Public Perceptions of Forest
Management in North Central Arizona: The Paradox of Demanding More Involvement but Allowing Limits to Legal
Action,” Journal of Forestry, v. 104 (Oct./Nov. 2006), pp. 375-382.
87 Jeffrey J. Brooks, Alexander N. Bujak, Joseph G. Champ, and Daniel R. Williams, Collaborative Capacity, Problem
Framing, and Mutual Trust in Addressing the Wildland Fire Social Problem: An Annotated Reading List, Gen. Tech.
Rept. RMRS-GTR-182 (Ft. Collins, CO: USDA Forest Service, Rocky Mountain Research Station, Nov. 2006).
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Conclusions
As more acres and more homes have burned in the past few years, and more people are at risk
from wildfires, Congress has faced increasing pressures to protect structures and resources.
Congress decides what programs to authorize and fund, and many options exist.
To protect homes, Congress could create new programs and expand existing ones for installing
non-flammable roofing, removing burnable materials adjacent to structures, and creating a
defensible space of at least 30 feet around the building. Programs could inform homeowners, or
assist or require landowner action; the programs could be federal or implemented through state or
local governments.
Protecting resources poses different challenges for Congress, because ecological damages vary
widely, depending on the ecosystem and on site-specific conditions. Fuel reduction can probably
moderate crown fire damages in surface fire ecosystems, and possibly in mixed-intensity fire
ecosystems. Existing programs for federal lands authorize prescribed burning (intentional fires
under prescribed conditions) and mechanical treatments (cutting and removing some trees), the
principal means of reducing fuel levels. However, prescribed fires are risky and mechanical
treatments can cause other ecological damages, and both are expensive. Proponents of more fuel
treatment advocate accelerated processes for environmental analysis and public review to reduce
costs and expedite action. Others caution that inadequate analysis and review can allow projects
with unintended damages and few fire protection benefits. Congress can alter the existing
environmental and public review processes, recognizing the trade-offs between expeditious action
and insufficient review. However, the fact is that crown fires occur; they cannot be halted and the
damages they cause cannot be totally prevented.
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Appendix. Excerpts from Forest Service Handbook
on NEPA Categorical Exclusions Related to
Structural or Resource Protection From Wildfires
The following materials are excerpts from the Forest Service handbook on NEPA categorical
exclusions—FSH 1909.15—Environmental Policy and Procedures Handbook. Chapter 30—
Categorical Exclusion from Documentation, Amendment No. 1909.15-2007-1 (February 15,
2007). Emphases (underscoring and boldface font) are in the original.
30.3 - Policy
...
2. Resource conditions that should be considered in determining whether extraordinary
circumstances related to the proposed action warrant further analysis and documentation in an EA
or EIS are:
a. Federally listed threatened or endangered species or designated critical habitat, species
proposed for Federal listing or proposed critical habitat, or Forest Service sensitive species.
b. Flood plains, wetlands, or municipal watersheds.
c. Congressionally designated areas, such as wilderness, wilderness study areas, or national
recreation areas.
d. Inventoried roadless areas.
e. Research natural areas.
f. American Indians or Alaska Native religious or cultural sites.
g. Archaeological sites, or historic properties or areas.
...
31.2 - Categories of Actions for Which a Project or Case File and Decision Memo Are
Required
...
6. Timber stand and/or wildlife habitat improvement activities which do not include the use of
herbicides or do not require more than one mile of low standard road construction.... Examples
include but are not limited to: ...
b. Thinning or brush control to improve growth or to reduce fire hazard including the opening
of an existing road to a dense timber stand.
c. Prescribed burning to control understory hardwoods in stands of southern pine.
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d. Prescribed burning to reduce natural fuel build-up and improve plant vigor.
...
10. Hazardous fuels reduction activities using prescribed fire, not to exceed 4,500 acres, and
mechanical methods for crushing, piling, thinning, pruning, cutting, chipping, mulching, and
mowing, not to exceed 1,000 acres. Such activities:
a. Shall be limited to areas:
(1) In the wildland-urban interface; or
(2) Condition Classes 2 or 3 [moderate or high risk of ecological damage] in Fire
Regimes I, II, or III [surface fire, stand-replacement fire at 35 years or less, and mixed-
intensity fire], outside the wildland-urban interface;
b. Shall be identified through a collaborative framework as described in “A Collaborative
Approach for Reducing Wildland Fire Risks to Communities and Environment 10-Year
Comprehensive Strategy Implementation Plan”;
c. Shall be conducted consistent with agency and Departmental procedures and applicable
land and resource management plans;
d. Shall not be conducted in wilderness areas or impair the suitability of wilderness study
areas for preservation as wilderness; and
e. Shall not include the use of herbicides or pesticides or the construction of new permanent
roads or other new permanent infrastructure; and may include the sale of vegetative material
if the primary purpose of the activity is hazardous fuel reduction.
...
12. Harvest of live trees not to exceed 70 acres, requiring no more than ½ mile of temporary road
construction. Do not use this category for even-aged regeneration harvest or vegetation type
conversion. The proposed action may include incidental removal of trees for landings, skid trails,
and road clearing. Examples include but are not limited to:
a. Removal of individual trees for sawlogs, specialty products, or fuelwood.
b. Commercial thinning of overstocked stands to achieve the desired stocking level to
increase health and vigor.
13. Salvage of dead and/or dying trees not to exceed 250 acres, requiring no more than ½ mile of
temporary road construction. The proposed action may include incidental removal of live or dead
trees for landings, skid trails, and road clearing. Examples include but are not limited to:
a. Harvest of a portion of a stand damaged by a wind or ice event and construction of a short
temporary road to access the damaged trees.
b. Harvest of fire-damaged trees.
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14. Commercial and non-commercial sanitation harvest of trees to control insects or disease not
to exceed 250 acres, requiring no more than ½ mile of temporary road construction, including
removal of infested/infected trees and adjacent live uninfested/uninfected trees as determined
necessary to control the spread of insects or disease. The proposed action may include incidental
removal of live or dead trees for landings, skid trails, and road clearing. Examples include but are
not limited to:
a. Felling and harvest of trees infested with southern pine beetles and immediately adjacent
uninfested trees to control expanding spot infestations.
b. Removal and/or destruction of infested trees affected by a new exotic insect or disease,
such as emerald ash borer, Asian long horned beetle, and sudden oak death pathogen.
Author Contact Information
Kelsi Bracmort
Specialist in Agricultural Conservation and Natural
Resources Policy
kbracmort@crs.loc.gov, 7-7283
Acknowledgments
This report was originally written by Ross Gorte, retired CRS Specialist in Natural Resources
Policy.
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